Programs authorized under PRWORA, as well as long-standing tribal programs, provide services related to the objectives of WtW. None of the 10 grantees in the study operated its WtW program independently from other employment and training programs. Each grantee provided services funded by the WtW grant as part of an existing employment-related program and used WtW funds to enhance and expand the services provided. For small tribes (for example, Kickapoo, Nez Perce, Klamath), the WtW funding level was sufficient to pay the wages of one staff member or a portion of the wages for several staff members, with the remaining funds used to provide services (described in Chapter IV).

The use of WtW funds varied, depending on whether the tribe operated a 477 program or a tribal TANF program. The seven grantees in the study that did not operate 477 programs used WtW funds to expand or enhance employment and training services specifically for WtW-eligible participants. Tribes that operated integrated 477 programs (three study grantees) used WtW funds to expand or enhance services in accordance with the goals of their 477 plans.

Most tribes have an agency or department responsible for helping tribal members become job ready and obtain employment. Most WtW grantees provide a range of employment-related services drawing on funds from different programs such as NEW and JTPA and from child care funding sources as appropriate and allowed. Depending on the size of the tribe, one person or office may administer the WtW, NEW, and JTPA programs (for example, Kickapoo), or many employees may be stationed at a variety of sites operating the programs (for example, Navajo Nation, California Indian Manpower Consortium, Tanana Chiefs Conference).

The place of the employment and training agency (E&T) within the tribe's organizational structure varies. For 8 of the 10 grantees in the study, the E&T agency is a component of a larger department or division (such as workforce development, human resources, employment, education, or labor). For two of the grantees (California Indian Manpower Consortium and Red Lake), the E&T agency is independent, reporting only to the head of the executive branch (tribal chairman, governor, president, chief, executive director) and to the tribal legislature (tribal council, business committee, corporation board).

Three of the grantees in the study (Nez Perce, Three Affiliated Tribes, White Earth) operate 477 programs that include WtW funding. When WtW funding is incorporated in a 477 program, there may be no distinct WtW program component; as with other 477 program funding, the WtW funds may be reprogrammed to meet the 477 program goals. Each of the three 477 programs in the study is operated under a tribal agency or department such as education, Tribal Employment Rights Office (TERO), or the tribal college.

The 477 program represents a dramatic departure from the way tribes traditionally have administered federally funded programs. Using the 477 approach, a tribe can combine funding from different federal programs without having to adhere to some of the limitations and requirements associated with specific programs or funding agencies. The tribe can define and deliver a set of integrated services in accordance with the tribe's goals and priorities. The 477 tribes in the study used service integration and case management approaches to administer unique programs. To do so, they drew on funding from WtW, NEW, vocational education, vocational rehabilitation, adult education, and other programs funded by ED, DHHS, the Department of the Interior, and DOL.(4)

While incorporating WtW, TANF, and other related programs into a 477 program has potential advantages, some problems have been encountered. The 477 approach can facilitate the development of a one-stop approach, as well as pooling of funds/resources to meet tribally determined goals. Support services, employment, training, child care, and other services or activities can be managed directly in conjunction with the TANF program. If each program is operated separately (outside 477), then the tribal units often have to implement some system of linkages, which can make service integration more difficult, although still possible. On the other hand, some problems have occurred in the release of FY 2002 NEW and CCDF funds to the 477 tribes through the BIA; in addition, some federal program administrators have raised concerns about the adequacy of 477 grantee annual reports to demonstrate that federal funds have been expended in accordance with statutory or regulatory mandates. Tribal and federal informants reported that annual 477 reports had been expanded over the years to meet some of these concerns.

The Indian and Native American Employment and Training Coalition (INAETC) offers technical assistance to tribes that want to determine the advantages and disadvantages of implementing a 477 program. INAETC works with DINAP in DOL and the BIA to obtain and distribute information to tribes pertaining to employment, training, and other welfare-related programs.

While about one-third of the tribes that operate TANF programs operate them under the 477 program, none of the tribes in this study had done so. PRWORA requires tribal TANF programs operated under a PL 102-477, like all other TANF programs, to submit TANF reports. Therefore, one advantage of program integration under 477 is not gained with regard to TANF, a factor that may contribute to some tribes' decision not to incorporate TANF in a 477 program.

Tribes in the study that participate in the 477 program were enthusiastic about it. Informants said that the 477 approach promotes Indian self-determination and self-governance, as well as service integration. These tribes had reassessed their goals and priorities with respect to education, training, and employment as part of designing and developing their 477 programs. They reported that they were better able to develop comprehensive approaches to interrelated education, employment, and training problems and conditions less fettered by the priorities, requirements, and approaches specified by separate programs and agencies.

For tribes, the TANF program dwarfs the WtW and NEW programs--a tribe's TANF grant is often more than 10 times greater than its WtW or NEW grant. Moreover, TANF is likely to continue to exist (especially in Indian country, with its high levels of unemployment), whereas WtW funding was available for only two federal funding cycles. The size and resources required to run a TANF program have deterred many tribes and tribal consortia from taking over TANF operation. However, tribal operation of TANF is also seen as a solution to difficulties in coordinating services with state TANF programs or differences in interpretation or application of state TANF rules to the tribe.

Although tribal takeover of TANF can improve service integration for tribal members, there is also a risk of at least temporary inefficiencies in program administration. Tribal takeover of TANF, combined with a tribal WtW grant, extends the range of program resources that can be provided to tribal members in a closely coordinated fashion consistent with tribal traditions and values. On the other hand, it is difficult to integrate information resources for WtW and TANF with the other tribal programs. In some cases, WtW and TANF staff develop separate information systems that are not designed with future integration in mind. This sometimes leads to incongruous results. A tribal TANF client may report a change of address to a WtW case manager, but it is not communicated to the TANF files; consequently, a TANF check may be mailed to an incorrect address. Basic information on tribal clients can be redundantly entered by several different staffs to separate systems.

In the sites examined for this study, tribal TANF and WtW programs operate out of separate agencies. Four of the grantees (Klamath, Navajo Nation, Nez Perce, and Tanana Chiefs Conference) operate a TANF program. In keeping with the intent of the WtW legislation, their WtW programs are administered through workforce agencies rather than welfare agencies, just as is true for state WtW grantees. Staff at the tribal E&T program (partially funded by the WtW grant) and TANF staff do not report to the same program manager, and at each of the four tribal TANF grantees, the TANF and E&T programs are in different departments or agencies. This separation can impede coordination and integration of the services and activities of the TANF and WtW programs. For example, at Klamath, the TANF and WtW offices are in communities more than 20 miles apart, and it is difficult for tribal members to travel from one office to the other. On the other hand, at Tanana Chiefs Conference, the WtW and TANF staffs are at least located in the same facility.

The administration of TANF and WtW programs by different tribal departments or agencies sometimes impedes welfare reform implementation efforts. For the tribes in the study, TANF tends to come under the aegis or influence of tribal social services programs, whereas WtW tends to come under the aegis of E&T or workforce development programs. While tribal officials and program managers embrace the goal of moving TANF recipients from welfare to work, it is difficult to restructure long-standing departments, programs, responsibilities, and ways of providing services. Such reorganization requires agreement among tribal members, the tribal council, and tribal administrators, as well as the expenditure of resources that are scarce for many tribes.

Program coordination presents a special challenge to tribes. In addition to internal coordination with other tribal services, tribal WtW programs must coordinate their activities with state- and county-administered programs, especially TANF. In addition, many tribes face constraints not faced by states or counties that limit service coordination (e.g., lack of economy of scale associated with small population size, challenges of enforcing child support orders of noncustodial parents residing and/or working off the reservation, and distance from state and county offices). Some tribal grantees in the study have developed promising strategies to address these constraints. These include (1) developing strategies for improved coordination with state/county TANF agencies, (2) combining program goals and funding under the 477 program, (3) coordinating with state agencies for child support enforcement, and (4) forming tribal consortia to improve operating efficiency.

Service coordination and integration have been the motivation for one-stop centers that promote a single application or intake process for multiple programs.(5) The unified intake permits application and eligibility determination for a range of services and programs funded by different federal agencies and departments, including food stamps, WtW, TANF, child support, transportation, and housing services. However, a tribal one-stop center generally cannot integrate services or programs that the tribe does not manage. Consequently, except for tribes operating TANF, none of the tribal programs in the study operated true one-stop centers. For example, if the tribe does not operate a TANF program, it cannot manage enrollment of tribal members in TANF and cannot integrate tribal services with TANF. Often, state or county one-stop centers are located far from tribal programs, making it difficult for tribal members to get to the center and for tribal staff members to coordinate with it. Service coordination is further limited because tribal staff members are often prohibited from accessing critical state or federal data needed for eligibility determination.

Several states where tribal study sites are located have addressed this disconnect between state TANF and tribal programs through co-location or outstationing of state staff at tribal programs. Alaska, Arizona, Minnesota, and North Dakota, or counties in these states, station TANF and other program staff on the reservation to serve tribal members. The state of Alaska took the innovative step of stationing state employees at the Tanana Chiefs Conference facility in Fairbanks to facilitate service coordination and provide convenient access to services. State staff at the Tanana Chiefs Conference facility also serve nontribal Alaska residents. The presence of state staff at the Tanana Chiefs Conference facility creates a one-stop center. The operation of one-stop centers serving all eligible citizens at a tribal facility improves the quality and efficiency of services provided to both tribal members and state residents. It is also a testament to cooperation and collaboration between the state and tribe.

Some state TANF programs may not provide the full complement of services to tribal members residing on reservations with high levels of unemployment. Some study informants said that state programs make little or no attempt to train and place TANF recipients who receive waivers from the 60-month lifetime limit as a result of residing on reservations where the not-working rate exceeds 50 percent. On such reservations, business and economic development are prerequisites for moving TANF recipients from welfare to work. Nevertheless, informants said that TANF, WtW, and other programs should provide skills enhancement, job training, work experience and other services to TANF recipients to help them to become ready and able to work when work becomes available.

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